Ann Foreman told the NSW Supreme Court on Thursday that Katie Foreman, 31, was “my rock, my pride and joy and I feel completely lost without her”.

In an emotional victim impact statement, Mrs Foreman said: “I see her in my dreams, I hear her screaming ‘mum, mum’.

“My dreams and waking thoughts are haunted by such images.

“I can’t fathom how anyone could perpetrate such violence on another human being.”

In April, Ms Foreman’s estranged partner, Bradley Max Rawlinson, was found guilty of murder by a jury.

During the sentencing hearing on Thursday, his barrister, Winston Terracini, SC, said Rawlinson maintains he is not guilty of murder but guilty of manslaughter.

Mr Terracini said Rawlinson should not be given a life sentence because he was not physically involved in lighting the fire at Ms Foreman’s Corrimal home on October 27, 2011.

The Crown’s case was that Rawlinson colluded with his alleged secret lover, Wendy Anne Evans, to kill Ms Foreman so the pair could be together.

It was alleged Evans, who pleaded guilty to murder, hired Michelle Sharon Proud and her de facto partner, Bernard Justin Spicer, to help carry out the crime.

The court heard Evans and Spicer went to Ms Foreman’s house and lit the fire that claimed her life.

The four individuals were each charged with Ms Foreman’s murder stemming from the allegation that they were part of a joint agreement – referred to as a “joint criminal enterprise” – to seriously harm or kill Ms Foreman.

Rawlinson, Proud and Spicer pleaded not guilty to murder.

Lawyers for Rawlinson had argued that their client only wanted Ms Foreman “scared” that evening, not dead, and had no knowledge that she would be killed.

His guilty plea for manslaughter was not accepted by the Crown.

Midway through the joint trial, Spicer was granted the right to a separate trial after a legal issue arose in his case.

During the sentencing hearing, Proud took the stand and told Justice Ian Harrison she was remorseful.

“I wish it was me that was dead instead of Katie,” Proud said.

Mrs Foreman said the “terrible lies” about her daughter’s sex life that were aired during the trial and the “character assassination” of Katie by certain witnesses caused her “much pain and anguish”.

Evans’ ex-boyfriend, Scott Field, told the court Evans and Ms Foreman were in a lesbian relationship and had engaged in sexual activity together.

Two Illawarra police officers said they had intimate encounters with Ms Foreman in the 12 months before her death.

A claim by another witness that Katie was pregnant when she died was proved incorrect.

“She was not pregnant ... and I as a mother know that my daughter was heterosexual,” Mrs Foreman said.

Mrs Foreman said she “can’t explain why she indulged in a lifestyle with a number of partners” but she felt Katie was settling down in the months leading up to her death.

“I will never, never forgive the perpetrators of this atrocity,” she said.

The Crown prosecutor, Chris Maxwell, QC, called for Rawlinson and Evans to receive a life sentence, saying their level of culpability was “extreme”. 

The hearing continues.